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05 May 2009

Unfair ERMA decision has wider implications

Few tears will have been shed when ERMA decided in December to ban the use of the insecticide endosulfan in New Zealand.

It was used only by a relative handful of horticultural growers and turf managers. It's also a particularly unpleasant product in its concentrated form - highly poisonous, an endocrine disrupter and a bio-accumulator. While it poses no known hazard when used as directed, its misuse and overuse overseas has led to human and environmental harm.

Horticulture New Zealand was apparently the only organisation to publicly register its dismay and their main gripe was with the one month's notice given before the ban went into effect. One month's notice over the Christmas-New Year period was clearly unreasonable in the context of a product that has been used in New Zealand in New Zealand for more than 50 years - for the most part uneventfully. There was no urgent threat associated with its continued use and the decision gave growers insufficient time to find alternative products or to adapt their growing methods.

Other primary industry observers may have been publicly silent. But there was a widespread suspicion that ERMA used endosulfan to demonstrate its evenhandedness with those green activists who had not forgiven ERMA for its decision a year before to sanction the continued use of 1080 to control possums.

We hope that wasn't the case. But the citrus growers who bear the main impact of the endosulfan decision have zero political clout, so they would have been an easy target. This is a big contrast with the economically important products used by major industries that ERMA now has on its 'to do' list.

Making ERMA's job even harder will be the decision of the European Parliament on 13 January to halve the use of ‘toxic' products in farming, with toxicity assessed on perceived hazard rather than a scientific assessment of risks and benefits. Although this decision (which was carried with a large majority) has yet to be ratified by EU member governments, it does highlight a change in official attitudes toward risk management, especially in Western Europe.

Already forest owners in New Zealand and overseas are battling with new Forest Stewardship Council pesticide rules initiated by European ENGOs that are impractical and lack scientific integrity. The resulting impasse now threatens the future of FSC eco-certification.

As an exporting nation, our products have to meet the standards of the marketplace, even if these standards are unscientific. Explaining risk management to the public is difficult at the best of times. But rationalising having less stringent standards applied at home than those applied abroad is on another scale of difficulty entirely.

The decision by the European Parliament ushers in an era in which ERMA will constantly have its public credibility put to the test. To come through without too many bruises, its best strategy will be to cultivate a reputation for rigour and fairness regardless of the economic clout of the industries affected.

What do you think?

P Clement
Excellent comment Trevor. You have clearly articulated the dilemma facing ERMA and NZ's rural productive sector, caused by the EU pursuing "hazard" based assessment rather than "risk". However ERMA can draw significant direction on which path to follow by the fact that their purpose is enshrined in NZ law via the HSNO Act including their name - Environmental RISK Management Authority. They have not be named EHMA!
Therefore there is no choice but to focus on risk. Apart from the hastiness of the Endosulfan decision I reckon they are developing a reputation for rigour and fairness.
Your encouragement surely helps that process.

Rongo
On the whole I agree with your comments. The Ag Compounds & Veterinary Medicines Unit at the NZ Food Safety Authority was somewhat gob smacked by the one month time frame, but of course could not say so publicly. Companies were annoyed as they had product on the sea ready for new season use. It has been accepted wisdom over the years that spreading these products thinly is the safest way to dispose of them, ie use them all up in their normal use pattern over a year. On the perception of risk vs real risk, former NZFSA communications manager Sandra Daly had the view that the NZFSA had to accept the perception of risk being the real risk to those people who perceived the risk. I think NZFSA is a bit smarter than that and their bottom line is usually science, but it does show how this attitude is infiltrating the bureaucracy. It\'s a populist approach really and my own view is that it is a cop out. If ERMA starts mixing politics and science, it will surely be its downfall.

Simon
Good to see some rational comment on this issue Trevor and encouraging to see that at least a few people out there recognise ERMA is attempting to operate in the real world and in general is doing a good job.

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